Although you may feel TRID issues are a thing of the past, you’d be wrong. It may seem fine from an origination standpoint, but from a company standpoint TRID is still an issue on the back end.
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Are the defects that are a result of TRID really material? Most of the defects are the result of following unrealistic disclosure requirements (such as the omission of the bar number of the closing attorney, or the “NMLS” number for a real estate agent (which does not exist, but some investors want it on page 5 of the CD anyway) and similar useless data required under TRID and settlement agents were never required to include on HUD-1s)is the real reason why the defect rate has increased. I doubt that settlement agents would or could do a better job on preparing the CD than lenders. The CD is not a document that tells the parties how funds will be disbursed at closing, and settlement agents do not have a database with accurate information for completing the contact list on page 5. The other major defect is the failure to make sure the borrower “receives” the LE 4 business days before closing and the initial CD 3 business days before closing. Lenders “deliver” them on time, but the borrowers don’t bother to look at them until a day or too late, and with electronic delivery the predominate method of delivery, a disclosure is not “received” until the borrower views it online. It’s the borrower’s fault, but the lender is blamed and pays the price. I am just glad we don’t get all of the government we pay for. I need a new bumper sticker for consumers: “I’m from the CFPB, and I am here to help”. Is there a complaint website to lodge complaints about the CFPB? I didn’t think so.
I will be in DC next week meeting with some House Representatives about Dodd/Frank and Trid, may I use your comment as one of the reports that I submit to each representative? Your first name will be included only.
Thanks,
Traci Chadbourne
Exit Bayshore Realty
Heritage Action Sentinel
Government regulations, BAD. Free markets, GOOD.
The problem with TRID is you have people doing these CD’s that do not understand the process on the lender side …..Then you have people from the settlement agent that think they are still in control and try to tell us how the loan is going to close….LOL..Oh one other thing the lender is responsible for the cds …but the title insurance company is insuring the closing….What a well thought out system …LOL…..Almost as bad as the new and improved Fannie Mae Loan application …I wonder why you havent done a show on that one …what a disaster waiting to happen when we start to use this one ….Do these people really have any common sense when they create these things??…Or do they ask the people in the field who actually do this on a daily basis??…prolly not …I guess the “K.I.S.S. Method” is something from the past…( That means “KEEP IT SIMPLE STUPID”)…..lol…Expect what is Inspected….and Inspect what is Expected ………… 🙂
I was a mortgage closer for a lender for nearly 5 years and I just recently left my job to pursue another career. Long story short, TRID crippled our closing department. Here is list of some reasons why:
– The waiting period to close: This caused much frustration from the LO to the customer. Some customers simply didn’t want to wait 3 days to close after the CD was acknowledged nor did some LOs want to wait either. This also caused a bottleneck of work on certain days. For example: on Tuesday we had high volume since the CD would need to be acknowledged Tuesday to close on that Friday. This caused heavy workloads and added stress.
– Discrepancies between LE and CD: Rarely did the LE match the final CD. Fees were always being added and subtracted, fee names changing, etc. etc… The LOs wouldn’t properly disclose fees up front and it soon became apparent that the transition from initial disclosure to final CD incurred many changes, thus confusing the customer
– Tension with settlement agents: Since settlement agents traditionally completed the HUD, they now relied on the lender to complete the CD, although this would cause many disagreements on fee placement, fee names, timing of the CD, etc. A complete role reversal surely caused much tension.
– Unnecessary information: Page 5 requires the NMLS #s, Real Estate license #s, and some other redundant information. This greatly delayed the CD process as this info wasn’t always readily available. Plus, we were defected if we left these areas blank (even if one line was left blank)… ridiculous
– Tolerance issues: The extra pre-cautious lender I worked for literally threw away money. Deciphering what and when to issue tolerance cures was frustrating and confusing. Prime example: Borrower did NOT select the title company so title fees are zero tolerance. Well, the LO disclosed fees one way and the CD would end up with different fee names/amounts. Anything beyond the threshold would cause a cure… tons of tolerance issues came about
Hopefully TRID will become more smooth and it has to start upstream. The LOs need to disclose things properly and the process needs to be more streamlined. Closing sure did become a lot more complicated and stressful
If everyone in class gets an F. Is it the students fault?
NEW TOPIC TO DISCUSS- APPRAISERS-PROTECTED, ROTATED, BEHOLDING TO NO ONE, AND CHANGING THE RULES. IT IS DIFFICULT TO GET THEM REMOVED FROM THE APPROVED LIST, BUT WHAT HAPPENS WHEN FEMALE APPRAISERS, DECIDE THAT THEY WILL NOT DO ANY APPRAISALS AFTER 2:30 PM CITING SAFETY ISSUES. WE DID NOT HIRE THEM FOR LESS THAN AN 8-5 AGREEMENT. ARE WE ABLE TO PROVIDE THEM ALL A SERVICE LEVEL AGREEMENT, AND SPELL OUT OUR REQUIREMENTS, FEES, ETC… AND THEY EITHER SIGN OR NOT. OR IS IT TOO LATE. IT IS TIME TO REVIEW OUR ROTATED APPRAISERS